ML20199H371

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SER Accepting Approving Request Relief from Requirements of Section XI, Rule for Inservice Insp of NPP Components, of ASME for Current or New 10-year Inservice Insp Interval IAW 50.55(a)(3)(i) of 10CFR50
ML20199H371
Person / Time
Site: Grand Gulf, Arkansas Nuclear, River Bend, Waterford  Entergy icon.png
Issue date: 11/19/1997
From:
NRC (Affiliation Not Assigned)
To:
Shared Package
ML20199F499 List:
References
NUDOCS 9711260099
Download: ML20199H371 (20)
v • d • e


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ORIGINAL SIGNED BY:.

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Docket No.4:

50-313, 50-368, 50-416, i

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50-458, and 50-382 1;

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Enclosure:

Safety Evaluation

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E. Adensam (EGAl)

D. Wigginton J. Donohew

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P. Gwynn, RIV-ACRS OGC-(15B18)

C.-Hawes-WBeckner G.'Bagchi

=T.- McLellan T. Harris (TLH3)

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Entergy Operations, Inc.

Arkansas Nuclear One, Units 1 1 2 CC' Executive Vice President Vice President, Operations Support'

& Chief Operating Officer Entergy Operations, Inc.

Entergy Operations, Inc.

P. O. Box 31995 P. O. Box 31995 Jackson, MS 39286-1995-Jackson, MS 39286-1995 Director, Division of Radiation Wise, Carter, Child & Caraway Control and Emergency Management P.~ 0. Box 651 Arkansas Department of Health Jackson, MS 39205 4815 West Markham Street, Slot 30 Little Rock, AR 72205-3867 Mr. C. Randy Hutchinson Vice President Operations, ANO Entergy Operations, Inc.

Winston &::i ' awn 1448 S. R. 333

-1400 L Street. N.W.

Russellville, AR 72801

-Washirgton, DC 20005-3502 Manager, Rockville Nuclear Licensing Framatone Technologies 1700 Rockville Pike, Suite 525 Rockville, MD 20852 Senior Resident Inspector U.S. Nuclear Regulatory Comission P. O. box 310 London, AR 72847' Regional Administrator, Region IV

- U.S. Nuclear Regulatory Cownission 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 County Judge of Pope County Pope County Courthouse Russellville, AR 72801

Entergy Operations, Inc.

Grand Gulf Nuclear Station cc:

-Executive Vice President General Manager, GGNS

& Chief Operating Officer Entergy Operations, Inc.

Entergy Operations, Inc.

P. O. Box 756 P. O. Box 31995 Port Gibson, MS 39150 Jackson, MS 39286-1995 Attorney General Wise, Carter, Child & Caraway Departnant of Justice P. O. Box 651 State of Louisiana Jackson, MS 39205 P. O. Box 94005 Baton Rouge, IA 70804-9005

-Winston & Strawn 1400 L Street, N.W. - 12th Floor State Health Officer Washington, DC 20005-3502 State Board of Health P. 0. Box 1700 Director Jackson, MS 39205 Division of Solid Waste Management Mississippi Department of Natural Office of the Governor Resources State of Mississippi P. O. Box 10385 Jackson, MS 39201 Jackson, MS 39209 Attorney General President, Asst. Attorney General Claiborne County Board of Supervisors State of Mississippi P. O. Box 339 P. O. Box 22947 Port Gibson. MS 39150 Jackson, MS 39225 Regional Administrator, Region IV Vice President, Operations Support U.S. Nuclear Regulatory Commission Entergy Operations, Inc.

611 Ryan Plaza Drive, Suite 1000 P.O. Box 31995 Arlington, TX 76011 Jackson, MS 39286-1995 Senior Resident Inspector Director, Nuclear Safety U. S. Nuclear Regulatory Commission and Regulatory Affairs Route 2, Box 399 Entergy Operations, Inc.

Port Gibson, MS 39150 P.O. Box 756 Port Gibson, MS 39150 Hanager of Operations Bechtel Power Corporation P.O. Box 2166 Houston, TX 77252-2166 Mr. Joseph J. Hagan Vice President, Operations GGNS Entergy Operations, Inc.

P. 0. Box 756 Port Gibson,.MS 39150 l

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Entergy Operations, Inc.

River Bend Station cc: '

Winston & Strawn Executive Vice President and 1400 L Street, N.W.

Chief Operating Officer Washington, DC 20005-3502

.Entergy Operations, Inc.

P. O. Box 31995 Manager - Licensing Jackson, MS 39286 Entergy Operations, Inc.

River Bend Station General Manager - Plant Operations P. O. Box 220 Entergy ups.ations, Inc.

St. Francisville, LA 70775 River Bend Station P. O. Box 220-Director-St. Francisville, LA 70775 Joint Operations Cajun

.10719 Airline Highway Director - Nuclear Safety P. O. Box 15540 Entergy Operations, Inc.

Baton Rouge, LA 70895 River Bend Station P. O. Box 220 Senior P.esident Inspector St. Francisville, LA 70775 P. O. Box 1050 St. Francisville, LA 70775 Vice President - Operations Support Entergy Operations, Inc.

President of West Feliciana P. O. Box 31995 Police Jury Jackson, MS 39286-1995 P. O. Box 1921 St. Francisville, LA 70775 f.ttorney General State of Louisiana Regional Administrator, Region IV P. O. Box 94095 U.S. Nuclear Regulatory Commission Baton Rouge, LA 70804-9095 611 Ryan Plaza Drive, Suite 1000 Arlington,~TX 76011 Wise, Carter, Child & Caraway P. O. Box 651 Ms. H. Anne Plettinger Jackson, MS 39205 3456 Villa Rose Drive Bator. Rouge, LA 70806 Vice President & Controller Cajun Electric Power Cooperative Administrator 10719 Airline Highway Louisiana Radiation Protection Division P.O. Box 15540 P. O. Box 82135 Baton Rouge, LA 70895 Baton Rouge, LA 70884-2135 Mr. John R. McGaha Vice President - Operations Entergy Operations, Inc.

River-Bend Station P.O. Box 220 St. Francisville, LA 70775-i s

'E tn ergy Operations,-Inc.

Waterford 3 cc:

Administrator _

Regional Administrator, Region IV Louisiana Radiation Protection Division U.S. Nuclear Regulatory Commission Post Office Box-82135 611 Ryan Plaza Drive, Suite 1000 Baton-Rouge, LA 70884-2135 Arlington, TX 76011 Vice President, Operations Resident Inspector /Watorford NPS Support Post Office Box 822 Entergs Operations, Inc.

Killona, LA 70066 P. O. Box 31995 Jackson, MS -39286-Parish President Council St. Charles Parish P. O. Box 302 Director Hahnville, LA 70057 Nuclear Safety & Regulatory Affairs-Entergy Operations, Inc.

P. 0. Box B Executive Vice-President Killona, LA 170066 and Chief Operating Officer Entergy Operations, Inc.

Wise, Carter, Child & Caraway P. O. Box 31995 P. O. Box 651 Jackson, MS 39286-1995 Jackson, MS - 39205 Chairman General Manager Plant Operations Louisiana Public Service Commission Entergy Operations, Inc.

One American Place, Suite 1630 P. O. Box B Baton Rouge, LA 70825-1697 Killona, LA 70066 Licensing Manager Vice President Operations Entergy Operations, Inc.

Entergy Operations, Inc.

P. O. Box B P. O. Box B Killona, LA 70066 Killona, LA 70066 Winston & Strawn 1400 L-Street, N.W.

Washington, DC 20005-3502 f

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UNITED STATES u

,j-NUCLEAR RE2ULATCRY COMMISSIGN WASHINGTON, D.C. 30866-0001

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SAFETJ _ EVALUATION _BY THE OFEICE OF NUCLEAR REACTOR REGULATION RELATED T0___RE00ESTS FOR RELIEF _TO USE ASME CODE CASES N-509. N-524. AND N-546 ENTERGJ_0PERATI_0NS. INC.. ET AL.

ARKANSAS NUCLEAR ONE. UNITS I & 2

_ GRAND G_ULF NUCLEAR STATION. UNIT 1 RIVER _ BEND STATION WATERF0_RD 3 STEAM ELECTRIC STATION DOCKET NOS. 50-3]3_. 50-368.__50-416. 50-458._AND 50-382 1.0 INTRODtlCTION By letters dated June 20, 1996 (3 letters), and January 14, May 12, and July 29, 1997, Entergy Operations, Inc. (the licensee or E01) requested relief from the requirements of Section XI, " Rules for Inservice Inspection of Nuclear Power Plant Components," of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (i.e., ASME Code or the Code) for the current or new 10-year inservice inspection (ISI) interval in accordance with Paragraph 50.55a(a)(3)(1) of 10 CFR Part 50 for the following plants:

Arkansas Nuclear One, Units 1 and 2 (ANO), Grand Gulf Nuclear Station, Unit 1 (GGNS), River Bend Station (RBS), and Waterfer<1 3 Steam Electric Station (Waterford 3). The current and new 10-year ISI interval for each plant is listed in Section 2.0 below.

In the letters of June 20, 1996, the licensee requested approval of the use of ASME Code Cases N-508-1, N-509, N-524, and N-546 for the above Entergy plants.

The letters of Jannary 14, May 12, and July 29, 1997, provided additional information neede< Dy the staff on these code case.

In the letters of October 7,1996 (for GGNS), and July 30, 1997 (for ANO, RBS, and Waterford 3),

we approved the use of Code Case N-508-1 for the four Entergy plants.

This evaluation concerns the use of the remaining code cases, Code Cases N-509, N-524, and N-546, for the four Entergy plants.

2.0 flACKGROUNIl The Technical Specifications (TS) for ANO, Units 1 and 2, Grand Gulf Nuclear Station, River Bend Station, and Waterford 3 Steam Electric Station, state that the inservice inspection-of the American Society of Mechanical Engineers (ASME) Code Class 1, 2, and 3 components shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel (B&PV) Code and applicable addenda as required by 10 CFR 50.55a(g), except where specific written relief has been granted by the Commission pursuant to 10 CFR 50.55a(g)(6)(i).

The

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_10 CFR 50.55a(a)(3) states that alternatives to' the requirements of paragraph (g):may be used, when authorized by the NRC, if 1) the proposed alternatives would provide-an acceptable. level of quality and(safety or (ii) compliance -

with the specified requirements would result in hardship or unusual difficulty l

without a compensating increase in the level of quality and safety.

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Pursuant to 10 CFR 50.55a(g)(4), ASME Code Class 1, 2, and 3 components

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-(including supports) shall meet the requirements,. except the design and access provisions and the pre-service examination requirements, set forth in the ASME Code,Section XI, " Rules for Inservice Inspection of Nuclear Power Plant Components," to the extent practical within the limitations of design, _

l geometry, and materials of construction of the components.

The regulations require that inservice examination of components and system pressure tests conducted during the first ten-year interval and subsequent

~ intervals comply with the requ' rements in the latest edition and addenda of Section XI.of the ASME-Code' incorporated by reference in 10 CFR 50.55a(b) twelve months prior to the start of the 120-month interval, subject to the limitations and modifications listed therein. The applicable editions of Section XI of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel-Code for the _ subject plants,- along with the applicable inservice inspection (ISI) interval and interval start dates, are listed in i

the table below.

Table 1 -

Current Interval Current Interval New Inttrval Plant Interval End Edition / Addenda Edition / Addenda ANO-1 2nd 12/1996 80/W81 92/93A ANO-2 2nd 03/2000 86 GGNS lst 01/1997 77/S79 92/93A River Bend 1st 12/97 80/W81 92/93A Waterford 3 1st

-07/97 l

80/W81 92/93A 4

Pursuant to.10 CFR 50.55a(g)(5), if the licensee determines that conformance -

with an' examination requirement of Section XI of.the ASME Code is not.

practical for its facility, information shall be_ submitted to the Commission in support of that determination and a request made for relief from the ASHF i

-Code requirement. After evaluation of the determination, pursuant to E

10 CFR:50.55a(g)(6)(1), the Commission may grant; relief and may impose.

. alternative requirements that are determined to-be authorized by law, will not endanger life, property, or the common defense and security, and are otherwise

--in the_public_ interest,-giving due consideration to the burden upon'the l

-_ licensee that could result if-the requirements were imposed.

-l 3

4 In three separate letters dated June 20, 1997, related to ten-year interval

- inservice inspection program plans for ANO, Units 1 and 2, GGNS, RBS, and Waterford 3, the licensee requested approval of ASME Code Cases N-503, N-524, and N-546. Additional information was provided by the licensee in its letters dated January 14, May 12, and July 29, 1997.

3.0 EVALUATION The staff, with technical assistance from its contractor, the Idaho National Engineering and Environmental Laboratory (INEEL), has evaluated the information provided by the licensee in support of its ten-year inservice inspection interval program plan requests for alternatives for ANO, Units 1 and 2, GGNS, RBS, and Waterford 3.

Based on the information submitted, the staff adopts the contractor's conclusions and recommendations presented in the Technical Letter Report (TLR) attached.

The licensee's proposed alternative to use Code Cases N-509, N-524, and N-546 for specific Entergy plants and ISI intervals are noted in the tables below.

Table z N-509 N-524 N-546 Plant Current New Current New Current New Interval Interval Interval Interval Interval Interval ANO-1 X

X X

ANO-2 X

X X

GGNS X

X X

River Bend X

X X

X Waterford 3 X

X X

X The licensee's proposed alternatives have been evaluated and the bases for the use of Code Cases N-509, N-524, and N-546 are as follows:

A.

Code Case N-509. Alternative Rules for the Selection and Examination of Class 1. 2. and 3 Intecrally Welded Attachments.Section XI.

Division 1:

The ASME Code,Section XI, Examination Categories B-H, B-K, C-C, D-A, D-8, and D-C, requires volumetric or surface examination of 100% of the non-exempt integrally welded attachments. Pursuant to 10 CFR 50.55a(a)(3)(i), the licensee requested authorization to use

.. Code Case-N-509,' Alternative Rules for the Selection and Examination of Class 1, 2, and 3 Integrally Welded Attachments.

In the May 12,-

1997, response to the NRC's RAI, the licensee modified its proposed

- alternative by stating that the examination sample-size would equal or exceed 10% of the total number of integral attachments in all-non-exempt Class 1, 2, and-3 piping, pumps, and valves-.

Code Case N-509 provides-alternative requirements for selecting and examining integrally welded. attachments of piping and components.

-The alternative reduces the total number of examinations from that stated above to 10% of the welded attachments associated with the component supports: selected for examination under the 1990 Addenda, IWF-2510 requirements. However, for the E01 facilities seeking -

approval of this Code Case for the new interval, the 1992 Edition of IWF-2510 will be used in lieu of the 1990 Addenda as specified in the Code Case.

IWF-2510 as written in the 1990 Addenda and-the 1992.

Edition are the same, and if permitted, this will simplify development of E01 ISI program updates by minimizing the references to various Editions and Addenda of Section XI within E01 ISI programs.

This Code Case is a significant departure from original ASME requirements, but is supported by industry experience that has been gathered and-reviewed by ASME. As part of this Code action, ASME conducted an industry survey to determine the extent of integral welded attachment failures. The data that was collected from the survey (43 nuclear plants responded) concluded the following:

Over the past 20 years, a total of five integral attachment failures were reported.

The failures which were reported were identified as a result of connected support member deformation rather than during the scheduled examination of the integral attachment.

Of the five failures, only one resulted in leakage from the pressure boundary. The root cause was determined to be design failure.

Industry experience with integral attachments supports the findings of ASME in that scheduled ISI examinations of integral attachments at E01 facilities have not identified any failed attachments.

Additionally, paragraph 1.3(b) of the Code Case now requires that

-when welded-attachments are examined as a result of identified component support deformation and the results of these examinations exceed the applicable acceptance standards listed in Code Case N-509,' additional or successive examinations shall be performed when determined necessary based on an evaluation by the Owner. This change is more restrictive than Code-requirements.- Under current

' Code requirements, additional examinations are only required when

- the rejected item is found during scheduled ISI examinations.

. The licentee has proposed, as an alternative to the Code requirements, to apply the requirements of Code Case N-509 for the examination of integrally-welded attachments on Class 1, 2, and 3 components. This Code Case, in effect, reduces the number of examinations on integral attachment welds from the present 100% to 10%, selected in conjunction with the support sampling criteria listed-in Article IWF of the 1989 Code Edition. To ensure an appropriate sampling of attachment welds, the licensee modified its alternative to supplement the Code Case with a minimum examir.ition sample of 10% of all integral attachments to non-exempt Class 1, 2, and 3 piping, pumps, and valves.

Considering that most of the Code examination requirements are based on sampling to ensure the detection of service-induced degradation, extending the sampling philosophy to the integral attachment welds-will provide an equivalent level of quality and safety for these components.

Therefore, the licensee's proposed alternative, as modified, is authorized pursuant to 10 CFR 50.55a(a)(3)(1). The use noted in Table 2 of the Code Case is authorized for the interval (s)ished in a future above, or until such time as the Code Case is publ revision of Regulatory Guide 1.147. At that time, if the licensee interds to continue to implement this Code Case, the licensee should follow all provisions in Code Case N-509, with limitations issued in Regulatory Guide 1.147, if any.

B.

Code Case N-524. Alternative Examination Reaufrements for Lonaltudinal Welds in Class 1 and ? Ploina.Section XI. Division 1 The ASME Code,Section XI, Examination Category B-J, requires 100%

volumetric and/or surface examination of longitudinal piping welds as defined by Figure IWB-2500-8. The examination shall include at least one pipe diameter, but not more than 12-inches of each longitudinal weld intersecting circumferential welds required to be examined by Examination Categories B-J and B-F.

Examinati..

Categories C-F-1 and C-F-2, require 100% volumetric and/or surface examination, as defined by Figure IWC-2500-7, -12 nd -13, for 2.5t of each longitudinal weld intersecting circumferential welds examined. Pursuant to 10 CFR 50.55a(a)(3)(i), the licensee proposes to use Code Case N-524 in-lieu of the Code examination requirements for Class 1 and 2 longitudinal welds.

The alternative rules of Code case N-524 reduce the longitudinal weld examination length to that portion of the longitudinal weld contained within the examination volume of the intersecting circumferential weld.

ASME Section XI. requires the examination of one pipe diameter, but not more than 12 inches, of Class 1 longitudinal piping welds.

For Class 2 piping welds, the length of longitudinal weld required to be examined is 2.5 times the pipe thickness. These lengths are

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e measured from the intersection with the circumferential weld.

In accordance with Code Case N-524, Alternative basination Requirenents for longitudinal Welds in C1 ass 1 and Class 2 PIpfng, the licensee's proposes to examine only the portions of longitudinal weld within the examination area of the intersecting circumferential weld.

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Longitudinal welds are produced during the manufacture of the piping, not in the field as is the case for circumferential welds.

Consequently, longitedinal welds are fabricated under strict manufacturing standards, which provides assurance of structural integrity. These welds have also been subjected to the preservice and initial inservice examinations, which provide additional assurance of structural integrity. No significant loading conditions or material degradation mechanisms have been identified to date that specifically relate to longitudinal seam welds in nuclear plant piping. The most critical region of the longitudinal weld is the portion that intersects the circumferential weld.

Since this region will be examined during the examination of the circumferential weld, the licensee's alternative provides an acceptable level of quality and safety by providing adequate assurance of component integrity. Therefore, the licensee's proposed alternative, to use Code Case N-524, is authorized pursuant to 10 CFR 50.55a(a)(3)(i). The use of the Code Case is authorized for the interval (s) noted in Table 2 above, or until such time as the Code Case is published in a future revision of Regulatory Guide 1.147. At that time, if the licensee intends to continue to implement this Code Case, the licensee should follow all provisions in Code Case N-524, with limitations issued in Regulatory Guide 1.147, if any.

.C.

Code Case N-546. Alternative Reautrements for Qualification of VT-2 Examination Personnel.Section XI. Division 1 The ASME Code,Section XI, IWA-2300, requires that personnel performing VT-2 visual examinations be qualified in accordance with comparable levels of competency as defined in ANSI N45.2.6.

Pursuant to 10 CFR 50.55a(a)(3)(1), the licensee proposed to use Code Case N-546 in lieu of the requirements of IWA-2300 for VT-2 visual examination personnel.

In the supplemental letter dated July 29, 1997, the licensee provided additional discussion and modified its proposed alternative to include the following:

1) development of procedural guidelines for obtaining consistent, quality VT-2 visual examinations (in accordance with ASME Section XI, IWA-2210]; 2) documentation and l

maintainance of records to verify the qualification of persons I

selected to perform VT-2 visual examinations (in accordance with ASME Section XI, IWA-1400(k)], and 3) independent review and i

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. evaluation of leakage by persons other than those that performed the VT-2 visual examinations [in accordance with ASME Section XI, IWA-1400(n)).

In the letter of July 29, 1997, the licensee stated that the above three items were required by IWA-2210, IWA-1400(k), and IWA-1400(n),

respectively, because Code Case N-546 is an alternative to IWA-2300 and not an alternative to IWA-2210, IWA-1400(k), and IWA-1400(n).

Also, the licensee stated that if Code Case N-546 could be implemented with only the requirements in the code case that there were the following other ASME Section XI requirements not contained in Code Case N-546:

(1) VT-2 inspections requiring the oversight of an authorized inspector in accordance with IWA-1400(f), (2) VT-2 results evaluated in accordance with IWB/IWC/IWD-3000, and (3) corrective measures in accordance with IWA-5250.

The licensee stated that these three ASME Section XI conditions were required because the code case would be implemented as an alternative to only IWA-2300 and the above three ASME Section XI conditions would still be required.

In the letter, the licensee stated that it will comply with the above provisions of ASME Section XI when performing VT-2 inspections.

The Code requires that VT-2 visual examination personnel be qualified to levels of competency comparable to those identified in ANSI N45.2.6. The Code also requires that the examii '. ion personnel be qualified for near and far distance vision acuity.

In lieu of the Code requirements, the licensee proposed to implement Code Case N-546 for personnel performing VT-2 visual examinations; this Code Case includes the following requirements:

1.

At least 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> plant walkdown experience, such as that gained by licensed and nonlicensed operators, local leak rate personnel, system engineers, and inspection and nondestructive examination personnel.

2.

At least four hours of training on Section XI requirements and p1 tut specific procedures for VT-2 visual examination.

3.

Vision test requirements of IWA-2321, 1995 Edition.

The qualification requirements in Code Case N-546 are not significantly different from those for VT-2 visual examiner certification.

Licensed and nonlicensed oparators, local leak rate personnel, system engineers, and inspection and nondestructive examination personnel typically have a sound working knowledge of plant components and piping layouts. This knowledge makes them acceptable candidates for performing VT-2 visual examinations.

In addition to meeting the requirements contained in Code Case N-546,-the licensee's alternatives include procedural guidelines for consistent, quality VT-2 visual examinations, verify and maintain

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- records of the qualification of persons-- selected to perform VT-2 visual examinations,i and. perform independent reviews and evaluations of leakage by a person (s) other than those that performed the VT-2 visual examination ; Based on a review of Code Case N-546 and the--

modifications to the >roposed alternative to the Code requirements, a

the staff concludes tiat the proposed alternative will provide an acceptable level of quality and safety by providing adequate 4

assurance of component integrity.-

Therefore, the licensee's request to implement Code Case N-546 as-modified by the above six items is authorized pursuant to 10 CFR 50.55a(a)(3)(1). The use of the Code Case is authorized for the interval (s) noted in Table 2-above or until such time as the 4

Code Case is published in a future revision of Regulatory Guide 1.147. At that time, if the licensee intends to continue to implement this Code Case, the licensee should follow all provisions 4

-in Code Case N-546,.with limitations issued in Regulatory Guide 1.147, if any.

-4.

@!KLUSIONS The staff has reviewed the licensee's submittal and concludes that the-licensee's proposed alternatives regarding the use of Code Cases N-509, N-524, i

and N-546-provides an acceptable level of quality and safety by providing adequate assurance of. component integrity. Therefore, the licensee's proposed alternative to use the above Code Cases, is authorized pursuant to 10 CFR 50.55a(a)(3)(1). The use of Code Cases N-509, N-524, and N-546 are authorized for intervals for each plant noted above in Table 2, or until such time as the Code Case is published'in a future revision of Regulatory Guide 1.147. - At that time, if the licensee intends to continue to implement this code case, the licensee should follow all provisions in the above Code Cases, with limitations, if any, prescribed in Regulatory Guide 1.147.

Attachment:

. Technical Letter Report Principal Contributor:

Tom McLellan Date: = November 19, 1997 4

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IECMlICAL LETTER RERQBI PROPOSED ALTERNATIVES FOR ENTERGY OPERATIONS. INC.

ARKANSAS... NUCLEAR 0NE. UNITS.1 AND 2. DOCKET NUMBERS 50-413 AND 50-368 GRAW_ GULF NUCLEAR STATION. DOCKET NUMBER 50-416 RIVER BEE STATION, DOCKET NUMBER 50-458 WATERFORD 3 STEAM ELECTRIC STATION. DOCKET NUMBER 50-382

1.0 INTRODUCTION

By three separate letters dated June 20, 1996, the licensee, Entergy Operations, Inc., requested authorization to use Code Cases N-509, N-524 and N-546 as alternatives to the Code requirements for Arkansas Nuclear One (ANO), Units 1 and 2, Grand Gulf Nuclear Station (GGNS), River Bend Station, and Waterford 3 Steam Electric Station.

In a letter dated January 14, 1997, the licensee clarified the proposed alternatives.

In response to a Nuclear Regulator Commission (NRC) request for additional information (RAI), the licensee submitted further information and clarification in a letter dated May 12, 1997. Additional information regarding the use of Code Case N-546 was provided in a letter dated Jtly 29, 1997. The Idaho National Engineering and Environmental Laboratory (INEEL) staff has evaluated the information provided by the licensee in support of the proposed alternatives in the following section.

2.0 EVALUATION The licensee has submitted proposed alternatives for various plants and intervals.

Information regarding the applicable editions of Section XI of the American Society of Mechanical Engineers (ASME) Boiler and Pressura Vessel Code for the subject plants, along with the applicable inservice inspection (ISI) interval and interval start dates, are listed in the two tables below.

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\\ Table 1 Current Interval Current Interval New' Interval E1101 Interval

[Dd Edition / Addenda Edition / Addenda ANO-1 2nd 12/1996 80/W81 92/93A ANO-2 2nd 03/2000 86 GGNS lst 01/1997 77/S79 92/93A River Bend 1st 12/97 80/W81 92/93A Waterford 3 1st 07/97 80/W81 92/93A Table 2 N-509 N-524 N-546 Plant Current New Current New Current New Interval Interval Interval Interval Interval Interval ANO-1 X

X X

ANO-2 X

X X

GGNS X

X X

River Bend X

X X

X Waterford 3 X

X X

X The proposed alternatives have been evaluated and the bases for disposition documented below.

s A.

Use of Code Case N-509. Alternative Rules for the Selection and Examination of Class 1. 2. and 3 Intearally Welded Attachments.

Section XI. Division 1 Code Reouirement: Section XI, Examination Categories B-H, B-K, C-C, D-A,'D-B, and D-C, requires volumetric or surface examination of 100% of the non-exempt integrally welded attachments.

Licensee's Proposed Alternative:

Pursuant to 10 CFR 50.55a(a)(3)(i), the licensee requested authorization to use Code

Case N-509, Alternative Rules for the Selection and Examination of Class 1, 2, and 3 Integrally Welded Attachments.

In the'Nay-12, 1997, response to the NRC's RAI, the licensee co.ifirmed that the examination-sample size would erpel-or exceed 10% of the total number of integral attachmen'.s in' all non-exempt Class 1, 2, and 3 piping, pumps, and _ valves.

Licensee's Basis for the Pronosed Alternative (as stated):-

" Current.Section XI requirements for E01 facilities require 100% of non-integrally welded attachments in Examination Categories B-H, B-K-1 and C-C to be examined by a volumetric or surface examination, as applicable, and Examination Categories D-A, D-B, and D-C to be

- visually examined.

" Code Case N-509 provides alternative requirements for selecting and examining integrally welded attachments of piping and components.

The alternative reduces the total number of examinations from that stated above to 10% of the welded attachments associated with the component supports selected for examination under the 1990 Addenda, IWF-2510 requirements. However, for the E01 facilities seeking approval of this Code Case for the new interval, the 1992 Edition of IWF-2510 will be used in lieu of the 1990 Addenda as specified in

_. the Code Case.

IWF-2510 as written in the 1990 Addenda and the 1992 Edition are the same, and if permitted, this will simplify development of E01 ISI program updates by minimizing the references to various Editions and Addenda of Section XI within E01 ISI programs.

"This Code Case is a significant departure from original ASME requirements, but is supported by industry experience that has been gathered and reviewed by ASME. As part of this Code action, ASME conductedanindustrysurveytodeterminetheextentofintegral welded attachment failures. The data that was collected from the survey (43 nuclear plants responded) concluded the following:

"Over the past 20 years, a total of five integral attachment-failures were reported, "The failures which were reported were identified as a result of connected support member deformation rather than during the

> scheduled examination of the integral attachment,

  • 0f the five failures, only one resulted in leakage from the pressure boundary..The root cause was determined to be design failure.

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. "Our experience with integral attachments supports the findings of

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ASME in that scheduled ISL examinations of integral attachments at E01 facilities have not identified any_ failed attachments.

. Additionally, paragraph 1.3 (b) of the Code Case now requires that

-when welded attachments are examined as a result of identified component support deformation and the results of these examinations

.are required. This change is more restrictive than Code requirements. Under current Code requirements, additional examinations are only required when the rejected item is found-during scheduled ISI examinations.

" Supported by the research of the ASME, E01's experience, and the increased requirements for additional examinations when attachments are found to be unacceptable in conjunction with deformed supports, Code Case N~509 is believed to provide an. acceptable level of quality and safety."

Evaluation: The licensee has proposed, as an alternative to the Code requirements, to apply the requirements of Code Case N-509 for the examination of integrally-welded attachments on Class 1, 2, and 3 components.

This Code Case, in effect, reduces the number of examinations on integral attachment welds from the present 100% to 10%, selected in conjunction with the support sampling criteria listed in Article IWF of the 1989 Code Edition. To ensure an appropriate sampling of attachment welds, the licensee has committed to supplement the Code Case with a minimum examination sample of 10%

of all integral attachments to non-exempt Class 1, 2, and 3 piping, pumps, and valves.

Considering that most of the Code examination requirements are based on sampling to ensure the detection of service-induced degradation, extending the sampling philorophy to the integral attachment welds will provide an equivalent level cf quality-and safety for these components..Therefore, it is recommended that the licensee's proposed alternative be authorized pursuant to 10 CFR 50.55a(a)(3)(i). The use'of the Code Case should be authorized for the interval (s) noted in Table 2 above, or until such time as the Code Case is published in a future revision of Regulatory i

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' Guide 1.147. ' At that -time, if the~ licensee inton'ds-to continue to implement this Code' Case, the licensee:should follow all provisions i

in Code Case N-509,'with-limitations-issued in Regulatory Guide 11147, if anyi 1

B.

Use of Code Case N-524, Alternative Examination Reaufrements for Lonaftudinal Welds in Class 1 and 2 Pinina.Section XI. Division 1-Code Raouirement: -Examination Category B-J, requires 100%

volumetric and/or surface examination of longitudinal piping welds as' defined by Figure IWB-2500-8. The examination shall include at least'one pipe diameter, but not more than 12-inches of each~

longitudinal weld intersecting circumferential welds required to be examined by Examination Categories B-J and B-F.

Examination

' Categories C-F-1 and C-F-2, require 100% volumetric and/or surface

-l examination, as defined by Figure IWC-2500-7, -12.and -13, for 2.5t of each longitudinal weld interseemg circumferential welds examined.

Licensee's Proposed Alternative:

Pursuant to 10 CFR 50.55a(a)(3)(1), the licensee proposes to use Code Case N-524 in

-lieu of the Code examination requirements for Class 1 and 2 longitudinal welds.

' Licensee's Basis'for the Pronosed Alternative (as stated):

" Current Code requirements at E01 facilities require longitudinal.

welds in non-exempt Class 2 pipe to be examined for a distance of 2.5t from the intersecting point of the circumferential weld, and longitudinal welds in non-exempt class 1 pipe to be examined for a distance of at 1sast one pipe-diameter-but no more than twelve inches;from the intersecting point of the cir umferential weld.

"The alternative rules of Code Case N-524 reduce the longitudinal

- weld examination length to.that portion of the longitudinal weld contained-within the examination volume of the intersecting h

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- !a circumferential weld. 'In May '1993, Report 90-07-001 was prepared for the ASME Section XI Task Group on ISI Optimization, this report concluded that:-

' Twenty-five nuclear units were surveyed representing 319 cumulative-years of operation. Total number of longitudinal welds examined equaled 2,059 with twenty-three welds (1.1%)

identified with indications. Evaluation of the twenty-three longitudinal welds concluded that none of the indications were rejectable and all indications were non-sertica -induced.

"When considering the' operational loadings, residual stresses from fabrication and degradation mechanisms, examining the-circumferential weld to longitudinal weld intersection'is adequate, and examining the additional length currently required by ASME Section XI is not necessary.

"There are no significant loading conditions or known material degradation mechanisms currently evident that specifically relate to-longitudinal seam welds in nuclear piping.

"Although the alternative examination volumes provided by Ccde Case N-524 reduces the total length of longitudinal welds now examined by ASME Section XI, it does require the portions of longitudinal welds that are most susceptible to service induced degradation to be examinea as part of the circumferential weld seam.

Performing examinations to the extent described by Code Case N-524 provides a level-of safety and quality consistent with the level of safety and quality currently provided by the ASME Section XI rules being implemented at E01 facilities."

Evaluation: ASME Section-XI requires the examination of one pipe diameter, but not more than 12 inches, of Class 1 -longitudinal e

piping welds. For Class 2 piping welds, the length of longitudinal weld required to be examined is 2.5 times the pipe thickness.

These lengths are measured from the intersection with the circumferential weld.

In'accordance with Code Case N-524, Alternative E amination x

Requirenents for longitudinal Welds in Class 1 and Class 2 Piping,

. the licensee's proposes to examine only the po.tions of longitudinal weld within the: examination area of the intersecting circumferential weld.

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Longitudinal welds are produced during the manufacture of the piping, not in the field as is the case for circumferential welds.

Consequently. longitudinal welds are fabricated under strict manufacturing standards, which prsvides assurance of structural integrity. These welds have also been subjected to the preservice and initial inservice examinations, which provide additional assurance of structural integrity. No significant loading conditions or material degradation mechanisms have been identified to date that specifically relate to longitudinal seam welds in nuclear plant piping. The most critical region of the longitudinal welti is the portion that intersects the circumferential weld.

Since this region will be examined during the examination of the circumferential weld, the licensee's alternative provides an acceptable level of quality and safety.

Therefore, it is recommended that the litensee's proposed alternative, to use Code Case N-524, be authorized nursuant to 10 CFR 50.55a(a)(3)(1). The use of the Code Case should be authorized for the interval (s) noted in Table 2 above, or until such time as the Code Case is published in a future revision of Regulatory Guide 1.147. At that time, if the licensee intend:: to continue to implement this Code Case, the licensee should follow all provision:; in Code Case N-524, with limitations issued in Regulatory Guide 1.147,. if any.

i C.

yle of Code Case N-546. Alternative Reautrements for Qualification of VT-2 Examination Personnel.Section XI._ Division 1 Code Reouirement: Section XI, IWA-2300, requires that personnel performing VT-2 visual examinations be qualified in accordance hith comparable levels of competency as defined in ANSI N45.2.6.

Licensee's Proposed Alternatin:

Pursuant to 10 CFR 30.55a(a)(3)(1), the licensee proposed to use Code Case N-546 in lieu of the requirements of IWA-2300 for VT-2 visual examination personnel.

In the supplemental letter dated July 29, 1997, the

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licensee provided additionat discussion and committed to 1) develop j

procedural guidelines for obtaining consistent, quality VT-2 visual examinatio::s (in accordalece with ASME Section XI, IWA-2210);

2) document and maintain records to verify the qualification of I

personsselectedtoperformVT-2visualexaminations[inaccordance l

with ASME Section XI, IWA-1400(k)), and 3) implement independent review and evaluation of leakage by persons other than those that performed the VT-2 visual examinations [in accordance with ASME SectionXI,1400(n)).

Licensee's luis for the Prooogen Alternative (as stated):

  • Current Section XI reqdroments for E01 facilities recuire personnel who perform VT-2 examinations to be qualifiec in accordance with comparable levels of competency as defined in ANSI N45.2.6. Additionally, th' examination personnel will have natural l

or corrected near distance vhion aculty, in at least one eye eNivalent to a Snellen fraction of 20/20 or a Jaeger Number 1 on a i

standard Jaeger test. Also, they shall demonstrate a far distance

- acuity that <s equivalent to the near distance requirement at 15 ft.

Or a Snell fraction of 20/30 at 20 ft.

  • Code Case N-546 permits experienced plant personnel such as licensed and nonlicensed operators, local leak rate personnel, system engineers, and inspection and nondestructive examination personnel to perform VT-2 visual inspections without having to be certified to comparable levels of ANSI N45.2.6. However, the Code Case does require personnel performing VT-2 inspections to have:

(1)

"At least 40 hrs plant walkdown experience, suW as that gained by licensed and nonlicensed operators, local leak rate personnel, system engineers, and inspection and nondestructive examination personnel.

(2)- *At least (4) hours of training on Section XI requirements and plant specific proced'Jres for VT-2 visual examination.

(3)

" Vision test nquirements of IWA-2321,1995 Edition of ASME I

Section XI.

"The requirements of Code Case N-546 as an alternative to the requirements of ASME Section XI as currently implemented at E01's facility will provide an acceptable level of quality and safety.

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g-The qualification requirements in Code Case N-546 are not significantly different from the qualifications required for VT-2 i

visual examiner certification. Licensed and nonlicensed operators, local leak rate personnel, system engineers, and inspection and i

nondestructive examination personnel typically have a sound working l

knowledge of_ plant components and piping layouts. This knowledge makes them. acceptable candidates for performing VT-2 visual examinations.

Therefore, this alternative provides a level of safety and quality consistent with that which is currently provided 1

by the ASME Section XI rules being implemented at E01 facilities."

l i

In response to the NRC RAI the licensee stated:

l

  • The introduction to Regulatory Guide ~1.147 states, in part, that i

the use of specific Code Cases may be authorized by the Commission upon request pursuant to paragraph 50.55a(a)(3) which requires that proposed alternatives to the described requirements or oortions t

thereof provide an acceptable level of quality and safety.

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  • The ASME meets regularly to consider proposed additions and revisions to the Code and to formulate Code Cases to clarify the intent of existing requirements or provide new rules where rules are nonexistent, or as alternatives tc existing rules. ASME approved Code Cases are_isnued with a specified edition and addenda of applicability wr which the Code Case is applicable, j
  • Code Cases are typically written to address a specific topic or requirement and whan adopted the Code Case is used in conjunction with the Code to maintain a complete set of requirements.

Code Cases are not stand-alone documents and are applicable only as

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described.in the Code Case.

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  • This explanation is provided as Entercy's basis fcr the following response to the Staff's proposed conditions for use of Code Case N-546."

therequIrementsforVT-2examinationstobeperformedinaccordance with written procedures that meet the requirements of ASME Section V, Article g is contained in lWA-2210.

Entergy has not requested an alternative or relaxation of these requirements.

Therefore, if the NRC is not requiring actions above those already a

required by IWA-2210, then we believe that we meet the intent of the condition.

the requirement' for the Owner to maintain adequate evidence of t

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personnel qualification is contained in IWA 1400(k).

Entergy has not requested an alternative or relaxation of the owner's responsibilities as define 1 in IWA-1400. Therefore, if the NRC is t

not requiring actions above those already required by IWA-1400(n),

i then we believe that we meet the intent of the condition.

i

  • NRC Condition 3: Entergy performs independent reviews of safety related activities as described by Ertorgy's Quality Assurance l

Programs and their implementing procedures.

"This condition describes activities that are controlled through programs that implement 10 CFR Appendix B and not-ASME Section XI.

ASME Section XI, IWA-1400(n) requires the Owner to maintain the documentation of a Quality Assurance Program in accordance with Title 10. Code of Federal Regulations, Part 50, or ASME NQA-1, Parts

!! and !!!, Basic Requirements and Supplements.

  • Section XI provides criteria for the evaluation of conditions detected during Section XI inspections and examinations.Section XI does not require independent reviews or evaluations from psopic other than those performing the inspection or examination. This condition would result in a en#que requirrment not required by ASME e

Section XI for any imposed M c. ion XI inspections or examinations.

It is not clear as to the significance of this condition for this specific inspection compared to all other inspections and examinations required by ASME Section XI.

  • !mplementation of NRC Condition 3 would in some cases preclude the most knowledgeable individual of a system's operating characteristics and specifications from reviewing and evaluating unacceptable system leakage discovered during VT-2 examinations if that individual had initially identified the system leakage.

'If the NRC condition is intended to require independent review and evaluations that are in excess of those already required by Entergy's Quality Assurance Programs, additional clarification is necessary as this condition wou d affect Entergy's implementation of 10 CFR Appendix and not ASME Section XI. However, if the NRC's condition is to only reinforce those actions that are already addressed by our compliance with 10 CFR 50 Appendix B and our additional commitments to Regulatory Guide 1.33, then we believe that.we meet.the intent of the condition."

- 1 Evaluation: The Code requires-that VT-2 visual examination personnel be qualified to levels of competency comparable to those identified in ANSI N45.2.6.

The Code also requires that the examination personnel be qualified for near and far distance vision t

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In lieu of the Code requirements, the licensee proposed to implement Code Case N-546 for personnel performing VT-2 visual examinations; this Code Case includes the following requirements:

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1.

At least 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> plant walkdown experience, such as that gained by licensed and nonlicensed operators, local leak rate personnel, system engineers, and inspection and I wdestructive examination pern.inel.

2.

At least four hours of training on Section XI requirements and plant specific procedures for VT-2 visual examination.

3.

Vision test requirements of IWA-2321, 1995 Edition.

The qualification requirements in Code Case N-546 are not significantly different from those for VT-2 visual examiner certification.

Licensed and nonlicensed operators, local leak rate personnel, system engineers, and inspecticn and nondestructive examination personnel typically have a sound working knowledge of plant components and piping layouts.

This knowledge makes them acceptable candidates for performing VT-2 visual examinations, in addition to meeting the requirements contained in Code Case N-546, the licensee has committed to use proccdural guidelines for consistent, quality VT-2 visual examinations, verify and maintain records of the qualification of persons selected to perform VT-2 visual examinations, and perform independent reviews and evaluations of leakage by E. person (s) other than those that performed the VT-2 visual examination.

Based on a review of Code Case N-546 and the additional connitments made by the licensee, the INEEL staff believes that the proposed alternative to the Code requirements will provide an acceptable level of quality and safety.

Therefore, it is recommended thtt the licensee's request to implement Code Case N-546 with the additional commitments be authorized pursuant to 10CFR50.55a(a)(3)(1).

The use of the Code Case should be authorized i

. for the interval (s) noted in Ta'. ele 2 above, or until such time as the Code Case is published in a future revision of Regulatory Guide 1.147.

At that time, if the licensee intends to continue to impleme.it this Code Case, the licensee should follow all provisions in Code Case N-546, with r

limitations issued in Regulatory Guide 1.147, if any.

3.0 CONCLUSION

The INEEL staff has reviewed the licensee's submittal and concludes that the licensee's proposed alternatives regarding the use of Code Cases N-509, N-524, and N-546 proviu an acceptable level of quality and safety.

Therefore, it is recommended that the use of these Code Cases, as proposed by the licensee, be authorized pursuant to 10 CFR 50.55a(a)(3)(1).

The use of the Code Cases should be authorized for the interval (s) noted in Table 2 above, or until such time as the Code Cases are published in a future revision of Regulatory Guide 1.147. At that time, if the licensee intends to continue to j

implement these Code Cases, the licensee should follow all provisions listed in the Code Cases, with limitations issued in Regulatory Guide 1.147, if any.

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